Memorandum Findings of Fact and Opinion
IRWIN, Judge:
In these consolidated cases, respondent determined the following deficiencies in petitioners' Federal income taxes:
William A. Powe Trust, Docket No. 10704-78 Year Deficiency 1973 .............. $153,365.07 1974 .............. 1,187.54 William A. Powe, Docket No. 10705-78 Year Deficiency 1972 ........
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